Postal Rate Commission
Submitted 5/26/2005 4:42 pm
Filing ID: 44459
Accepted 5/26/2005
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268B0001
POSTAL RATE AND FEE CHANGES
PURSUANT TO PUBLIC LAW 108-18
Docket No. R2005B1
RESPONSES OF THE UNITED STATES POSTAL SERVICE TO INTERROGATORIES
OF DAVID POPKIN [DBP/USPS-56-58, 61, 64, 65 and 67]
The United States Postal Service hereby provides its responses to above-listed
interrogatories of David Popkin, filed on May 12, 2005. Each interrogatory is stated
verbatim and is followed by the response.
Objections to the following interrogatories were filed on April 18, 2005:
DBP/USPS-1, 2, 3, 5, 7, 9, 10, 12, 17-20 and 23.
Response to the remaining interrogatories not objected to are forthcoming.
Respectfully submitted,
UNITED STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
______________________________
Michael T. Tidwell
475 L'Enfant Plaza West, S.W.
Washington, D.C. 20260-1137
(202) 268-2998, Fax -5402
[email protected]
May 26, 2005
RESPONSE OF THE UNITED STATES POSTAL SERVICE TO
INTERROGATORY OF DAVID B. POPKIN
DBP/USPS-56
Please refer to your response to DBP/USPS-13 subpart f. Please confirm, or
explain if you are unable to do so, that the EXFC program also tests post cards.
RESPONSE: Confirmed.
2
RESPONSE OF THE UNITED STATES POSTAL SERVICE TO
INTERROGATORY OF DAVID B. POPKIN
DBP/USPS-57
Please refer to your response to DBP/USPS-13 subpart i. [a] Please elaborate on the
meaning of "controlled conditions". [b] Please advise what notice is given to potential
mailers under these conditions and if notice is not given, please explain why.
RESPONSE:
[a]
"Controlled conditions" are anticipated interruptions in collection service
forwhich
the Postal Service is able to plan adequately in advance, as opposed to uncontrolled
conditions such as sudden, adverse weather
[b]
conditions.
Information is usually posted at post offices and is distributed to the local news
outlets: newspapers, and radio and television news operations.
3
RESPONSE OF THE UNITED STATES POSTAL SERVICE TO
INTERROGATORY OF DAVID B. POPKIN
DBP/USPS-58
Please refer to your response to DBP/USPS-32 subpart a. Please reanswer the subpart
if one is to assume that the mailer will obtain a postmark or validation of the mailing
receipt in a similar manner that would be required in obtaining a Certificate of Mailing
which has to be postmarked to have any validity. Please also add PS Form 3804 Return
Receipt for Merchandise to the listing of other forms.
RESPONSE:
Not confirmed. While the postmark on any of these forms, including Form 3804, shows
receipt by the Postal Service, only Certificate of Mailing service provides the mailing
receipt on PS Form 3817, which may have a special significance to the mailer.
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RESPONSE OF THE UNITED STATES POSTAL SERVICE TO
INTERROGATORY OF DAVID B. POPKIN
DBP/USPS-59.
Please refer to your response to DBP/USPS-33 subpart c. Please confirm, or explain if
you are unable to do so, that the mailer must fill in this name and address prior to
mailing the article. Please also add PS Form 3804 Return Receipt for Merchandise to
the listing of other forms.
RESPONSE:
Not confirmed. However, the DMM does say that Forms 3800, 3804, 3817, and 11-B
must be filled out by the mailer.
5
RESPONSE OF THE UNITED STATES POSTAL SERVICE TO
INTERROGATORY OF DAVID B. POPKIN
DBP/USPS-61
Please refer to your response to DBP/USPS-38. [a] Please confirm that the CDrom
shows Standard Mail delivery standards of 3 to 10 days and that all 50 states are
shown. [b] Please confirm that the CDrom shows Package Services delivery standards
of 2 to 9 days and that only the 48 contiguous states are shown. [c] Please confirm
that the delivery standards in the 48 contiguous states for Package Services is equal to
or better than the standard for Standard Mail. [d] Please advise why it is believed that
this similar condition [Package Services equal to or better than Standard Mail] would not
also apply to locations other than the 48 contiguous states. [e] Please advise what
studies have been made to show that 3 to 5 weeks is a realistic estimate of delivery
time for Package Services to or from or within areas other than the 48 contiguous
states. Please provide copies of the studies. [f] Please confirm that mailers will utilize
this 35-day estimate in comparison to the times shown for Express Mail or Priority Mail
in making a decision as to which service to utilize. [g] Please confirm that the
maximum time shown for Express Mail or Priority Mail is 3 days. [h] Please explain any
subparts you are unable to confirm.
RESPONSE:
[a]
Confirmed.
[b]
Confirmed.
[c]
This is generally correct, but without analyzing each of the over 800,000
destination 3-digit ZIP combinations, it is not possible to confirm it
[d]
origin-
unequivocally.
The delivery estimates for Standard Mail and Package Services to offshore
locations should be similar, since the mail travels by ship,
sometimes two ships,
adding significant transit times.
[e]
Please see the attached information from Hawaii. The issues are
same for other offshore locations.
[f-g]
Confirmed.
[h]
N/A
6
generally the
Standard Mail Shipping Logistics
Continental U.S. and Hawaii
May 2001
Direct Mail is usually sent as USPS Standard Mail and often requires specific “in home” delivery dates. Standard Mail moves on many modes of surface transportation (e.g., trains, trucks
and ships), and only the most knowledgeable mailer is capable of accurately projecting delivery
dates. The attached maps are to help you better understand USPS logistics and the time
frames you may expect for transporting Standard Mail across the continent and to Hawaii.
Bulk Mail Center Locations
Standard Mail (formerly known as Third and Fourth Class Mail) is sorted and dispatched
through these dedicated facilities.
Honolulu District
San Francisco Bulk Mail Center and Mail Destined to Hawaii
San Francisco is a critical destination for mail entered on the continent and addressed to Hawaii because most mail destined for the islands’ travels through the
San Francisco Bulk Mail Center. The map below indicates the number of days
required to move Standard Mail from all points in the continental US to San
Francisco. On average, Standard Mail may take from one to ten days to arrive in
San Francisco depending on the site of origin.
Standard Mail Commitment Days from
continental locations to San Francisco
3 4 5 6 7 8 910
=
Commitment Days
San
Francisco
BMC
Colors on the map represent the number of days between entry and delivery. For
example, the average number of delivery days between the eastern portion of the
country and San Francisco is ten.
Honolulu District
Shipping Schedule from the West Coast to Hawaii
The Los Angeles Bulk Mail Center (BMC) ships mail originating in Southern California, and the San Francisco BMC ships mail from other entry locations nationwide.
The map below shows shipping routes and days of dispatch from these facilities.
To make connections out of either location, mail should be available at the local
BMC at least one day prior to the ship’s departure. Transit time from both locations is approximately 4 - 5 days.
Standard Mail Shipping Schedule
From the West Coast
Commitment (Days)
3 4 5 6 78 910
San Francisco Departure
Wed, Thu and Fri
Los Angeles Departure
Wed and Sat
Honolulu District
Origination
San Francisco
&
Los Angeles
Transporting Standard Mail to Islands Outside of Oahu
Standard Mail is shipped by barge from Honolulu to islands outside Oahu. As with
other modes of transportation, the USPS contracts with barge operators to move the
mail and Standard Mail is generally delivered within two to three days after receipt at
the outside islands port. To make connections on a barge, mail should be at the Honolulu Post Office at least one day prior to the ship’s departure. At dispatch time, full (and
half full) 1200 cubic foot containers will be sent to the docks for shipping.
Standard Mail Barge Schedule from Honolulu
Shown below is the shipping schedule for surface containers from Honolulu to
other Hawaiian Islands. Mail should generally be available at the USPS Plant in
Honolulu one day prior to departure.
Molokai (Wed, Sun)
Maui (Tue, Thu, Sun)
Kauai (Mon, Thu)
Lanai (Wed)
Honolulu, Oahu
Kawaihae, Hawaii (Thu, Sun)
Hilo, Hawaii (Sun, Wed)
Targeting Delivery Dates
Given the ten days it takes to cross the continent, and the five days to cross the Pacific
Ocean, Standard Mail entered on the east coast will be delivered in Honolulu in an average
of twenty-one days. Delivery time is generally longer during the heavier Fall mailing season. However, there are several ways to reduce delivery time throughout the year. For
example, when mailing to Hawaii, entering mail on the west coast is ten days faster than
entering on the east coast. Drop Shipping into Honolulu via Express Mail or Priority Mail
(from any point in the country) is at least five days faster than entering Standard Mail on the
west coast.
This report prepared by Gary Gardetto, Honolulu USPS Manager, Marketing
Honolulu District
RESPONSE OF THE UNITED STATES POSTAL SERVICE TO
INTERROGATORY OF DAVID B. POPKIN
DBP/USPS-64
[a] Please provide the average cost of processing a Registered
Mail claim. [b] Does the cost depend on the value of the claim? [c] If so, please provide
the average cost for each value bracket.
RESPONSE:
[a-c] The Postal Service does not have data on the average cost of processing a
Registered Mail claim, or whether the processing cost depends on the value of the
claim.
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RESPONSE OF THE UNITED STATES POSTAL SERVICE TO
INTERROGATORY OF DAVID B. POPKIN
DBP/USPS-65. Please refer to your response to DFC/USPS-22 subpart a. Please
advise how the mailer will know of this capability.
RESPONSE:
A customer might know by prior experience with obtaining Certified Mail receipts, or by
knowledge of DMM § 503.3.3.5d, which explains how to obtain a postmarked sender’s
receipt.
8
RESPONSE OF THE UNITED STATES POSTAL SERVICE TO
INTERROGATORY OF DAVID B. POPKIN
DBP/USPS-67
Please refer to your response to DFC/USPS-27. [a] Please confirm, or explain if you are
unable to do so, that the following criteria exist for evaluating the time for an EXFC test
letter: [1] If the scheduled service standard time for the letter is a delivery date and the
letter is delivered on that day, the EXFC tally will be that day. [2] If the scheduled service
standard time for the letter is a non-delivery date and the letter is delivered on next
available delivery date, the EXFC tally will the time of the scheduled delivery standard. [3]
The only way that an EXFC letter could show a tally which was less than the scheduled
delivery standard, such as a letter sent to a 3-day delivery area being tallied as 1 or 2 days,
would be for the letter to be physically delivered in that time. [4] If the letter is not delivered
by the scheduled service standard time and the day before the actual delivery day is a
delivery date, the EXFC tally will be the time of the actual delivery. [5] If the letter is not
delivered by the scheduled service standard time and the day[s] before the actual delivery
day is[are] a non-delivery date, the EXFC tally will be the number of days to the first nondelivery day so long as it will not show delivery in less time than the scheduled delivery
standard. [6] There are no arrangements of non-delivery days that would allow for the
EXFC tally to show a time which was less than the scheduled delivery standard, namely, a
letter sent to a 3-day area would not be tallied as being delivered in 1 or 2 days or a letter
sent to a 3-day area would not be tallied as being delivered in 1 day unless it actually got
delivered in that reduced time. [b] Are there any instances where a letter that is expected
to be inducted into the system on, for example, a Wednesday, is physically deposited in the
collection box on Tuesday? [c] If so, please explain. [d] Do the various criteria
enumerated in subpart a apply to all other systems that are utilized by the Postal Service to
measure the time of delivery of mail? [e] If not, please explain and provide details.
RESPONSE:
[a1-2] Yes.
[a3]
Not necessarily, see example #4.
[a4] – Yes.
[a5] – See examples for calculation of delivery day. The service standard is not
factored in to delivery day calculation
[A6] – No, see example #4.
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RESPONSE OF THE UNITED STATES POSTAL SERVICE TO
INTERROGATORY OF DAVID B. POPKIN
RESPONSE to DBP/USPS-67 (continued):
[b]
No
[c]
N/A
[d]
The criteria apply for EXFC, PETE and ODIS.
[e]
N/A
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